The American Council of Life Insurers (ACLI), the German Insurance Association (GDV), and the Life Insurance Association of Japan (LIAJ) said IASB's Draft Statement of Principles on Insurance Contracts poses numerous problems, particularly 'mark-to-market' accounting – "immediate recognition of the fair value of the estimated future profitability associated with insurance contracts, especially long-term contracts, sold during the reporting period.... Application of such an approach where there are no verifiable market prices leads to situations where entities are free to develop and use valuation models based on their own assumptions and methods.... There is no question about whether a theoretical model could be developed and required for insurance contracts. The real question is whether doing so would make matters better or worse.... We believe that the deferral/matching approach is appropriate and preferable for life insurance contracts." Click for ACLI-GDV-LIAJ Letter to IASB (PDF 186k).